A coalition of kid safety and privateness teams has filed a grievance with the Federal Trade Commission (FTC) urging it to analyze a kid-focused version of Amazon’s Echo good speaker.
The grievance in opposition to Amazon Echo Dot Kids, which has been lodged with the FTC by teams together with the Campaign for a Commercial-Free Childhood, the Center for Digital Democracy and the Consumer Federation of America, argues that the e-commerce large is violating the Children’s Online Privacy Protection Act (COPPA) — together with by failing to acquire correct consents for using children’ information.
As with its different good speaker Echo gadgets, the Echo Dot Kids regularly listens for a wake phrase after which responds to voice instructions by recording and processing customers’ speech. The distinction with this Echo is it’s supposed for kids to make use of — which makes it topic to U.S. privateness regulation supposed to guard children from business exploitation on-line.
The grievance, which could be learn in full through the group’s grievance web site, argues that Amazon fails to supply ample info to oldsters about what private information will likely be collected from their youngsters once they use the Echo Dot Kids; how their info will likely be used; and which third events it is going to be shared with — which means mother and father shouldn’t have sufficient info to make an knowledgeable determination about whether or not to provide consent for his or her little one’s information to be processed.
They additionally accuse Amazon of offering at greatest “unclear and confusing” info per its obligation beneath COPPA to additionally present discover to oldsters to acquire consent for kids’s info to be collected by third events through the net service — comparable to these offering Alexa “skills” (aka apps the AI can work together with to increase its utility).
Quite a few different considerations about Amazon’s gadget are additionally being raised with the FTC.
Amazon launched the Echo Dot Kids a yr in the past — and, as we famous on the time, it’s primarily a brightly bumpered iteration of the corporate’s commonplace Echo Dot .
There are variations within the software program, although. In parallel, Amazon up to date its Alexa good assistant — including parental controls, aka its FreeTime software program, to the child-focused good speaker.
Amazon stated the free model of FreeTime that comes bundled with the Echo Dot Kids offers mother and father with controls to handle their children’ use of the product, together with gadget deadlines; parental controls over abilities and providers; and the power to view children’ exercise through a parental dashboard within the app. The software program additionally removes the power for Alexa for use to make cellphone calls outdoors the house (whereas holding an intercom performance).
A paid premium tier of FreeTime (referred to as FreeTime Unlimited) additionally bundles extra kid-friendly content material, together with Audible books, ad-free radio stations from iHeartRadio Family and premium abilities and tales from the likes of Disney, National Geographic and Nickelodeon .
At the time it introduced the Echo Dot Kids, Amazon stated it had tweaked its voice assistant to help kid-focused interactions — saying it had skilled the AI to know youngsters’s questions and speech patterns, and integrated new solutions focused particularly at children (comparable to jokes).
But whereas the corporate was ploughing useful resource into including a parental management layer to Echo and making Alexa’s speech recognition kid-friendly, the COPPA grievance argues it did not pay sufficient consideration to the info safety and privateness obligations that apply to merchandise focused at youngsters — because the Echo Dot Kids clearly is.
Or, to place it one other approach, Amazon provides mother and father some controls over how their youngsters can work together with the product — however not sufficient controls over how Amazon (and others) can work together with their youngsters’s information through the identical always-on microphone.
More particularly, the group argues that Amazon is failing to satisfy its obligation because the operator of a child-directed service to supply discover and procure consent for third events working on the Alexa platform to make use of youngsters’s information — noting that its Children’s Privacy Disclosure coverage states it doesn’t apply to third-party providers and abilities.
Instead, the grievance says Amazon tells mother and father they need to assessment the ability’s insurance policies regarding information assortment and use. “Our investigation found that only about 15% of kid skills provide a link to a privacy policy. Thus, Amazon’s notice to parents regarding data collection by third parties appears designed to discourage parental engagement and avoid Amazon’s responsibilities under Coppa,” the group writes in a abstract of their grievance.
They are additionally objecting to how Amazon is acquiring parental consent — arguing its system for doing so is insufficient as a result of it’s merely asking that a credit score or debit/debit present card quantity be inputted.
“It does not verify that the person ‘consenting’ is the child’s parent as required by Coppa,” they argue. “Nor does Amazon verify that the person consenting is even an adult because it allows the use of debit gift cards and does not require a financial transaction for verification.”
Another objection is that Amazon is retaining audio recordings of youngsters’s voices far longer than mandatory — holding them indefinitely except a dad or mum actively goes in and deletes the recordings, regardless of COPPA requiring that youngsters’s information be held for now not than in all fairness mandatory.
They discovered that extra information (comparable to transcripts of audio recordings) was additionally nonetheless retained even after audio recordings had been deleted. A dad or mum should contact Amazon customer support to explicitly request deletion of their little one’s total profile to take away that information residue — which means that to delete all recorded children’ information a dad or mum has to nix their entry to parental controls and their children’ entry to content material offered through FreeTime — so the grievance argues that Amazon’s course of for folks to delete youngsters’s info is “unduly burdensome” too.
Their investigation additionally discovered the corporate’s course of for letting mother and father assessment youngsters’s info to be equally arduous, with no capacity for folks to go looking the collected information — which means they need to hear/learn each recording of their little one to know what has been saved.
They additional spotlight that youngsters’s Echo Dot Kids’ audio recordings can after all embody delicate private particulars — comparable to if a toddler makes use of Alexa’s “remember” characteristic to ask the AI to recollect private information comparable to their tackle and speak to particulars or private well being info like a meals allergy.

The group’s grievance additionally flags the danger of different youngsters having their information collected and processed by Amazon with out their mother and father’ consent — comparable to when a toddler has a buddy or member of the family visiting on a play date they usually find yourself taking part in with the Echo collectively.
Responding to the grievance, Amazon has denied it’s in breach of COPPA. In an announcement, an organization spokesperson stated: “FreeTime on Alexa and Echo Dot Kids Edition are compliant with the Children’s Online Privacy Protection Act (COPPA). Customers can find more information on Alexa and overall privacy practices here: https://www.amazon.com/alexa/voice [amazon.com].”
An Amazon spokesperson additionally informed us it solely permits child abilities to gather private info from youngsters outdoors of FreeTime Unlimited (i.e. the paid tier) — after which provided that the ability has a privateness coverage and the developer individually obtains verified consent from the dad or mum, including that the majority child abilities shouldn’t have a privateness coverage as a result of they don’t accumulate any private info.
At the time of writing, the FTC had not responded to a request for touch upon the grievance.
In Europe, there was rising concern over using youngsters’s information by on-line providers. A report by England’s youngsters’s commissioner late final yr warned children are being “datafied,” and recommended profiling at such an early age may result in a data-disadvantaged era.
Responding to rising considerations the U.Okay. privateness regulator launched a session on a draft Code of Practice for age applicable design final month, asking for suggestions on 16 proposed requirements on-line providers should meet to guard youngsters’s privateness — together with requiring that product makers put the perfect pursuits of the kid on the fore, ship clear T&Cs, reduce information use and set excessive privateness defaults.
The U.Okay. authorities has additionally not too long ago printed a whitepaper setting out a coverage plan to manage web content material that has a heavy deal with little one security.

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